News & Analysis as of

Operation Chokepoint and the Brave New World of Criminal Liability - November 2014

The U.S. Department of Justice and banking regulators have stepped up the pace of criminal, civil and administrative actions against banks, payment processors, money transmitters, and other financial institutions, for...more

"CFTC Fine-Tunes Rules, Emphasizing Relief for Commercial End-Users"

On November 3, 2014, the Commodity Futures Trading Commission (CFTC or Commission) approved three proposals that Chairman Timothy Massad described as “fine tuning” certain of the CFTC’s rules “to make sure they do not impose...more

Reading between the Headlines: A Lesson in Risk Mitigation from Edward Snowden

Whistleblowing has become a highly charged term, stirring up emotive rhetoric ranging from “ethical hero” to “treasonous traitor” with very little substantive evaluation of the real impact on the corporation and the broader...more

Proprietary Trading Aspects of the Volcker Rule – Frequently Asked Questions

The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission (the “SEC”) issued a final rule, and the Commodity Futures...more

SEC Adopts Changes to Broker-Dealer Net Capital and Financial Responsibility Rules

The US Securities and Exchange Commission recently adopted important changes to the financial responsibility rules for securities broker-dealers, including changes to the regulatory capital and regulatory reporting rules. The...more

EMIR – Summary of Key Requirements

The European Markets Infrastructure Regulation (EMIR) introduces requirements aimed at improving transparency and the reduction of risks associated with the derivatives market. EMIR also establishes organisational, conduct of...more

Implementing Measures of European Market Infrastructure Regulation Take Effect

New clearing, risk mitigation, and reporting obligations imposed on certain derivative contracts. On 15 March, the first six implementing measures of the European Market Infrastructure Regulation (EMIR) entered into...more

Reporting, clearing and risk mitigation rules for derivatives under European law in 2013 – the impact on buy side entities

A few provisions of the Regulation on Derivative Transactions, Central Counterparties and Trade Repositories, known as the European Market Infrastructure Regulation 648/2012 (“EMIR”) are now in effect throughout the European...more

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